PRIVACY POLICY

ADDURNO.COM PORTAL

This Data Protection Policy has been prepared in accordance with the applicable legislation in Andorra, Law 29/2021 of 28 October on the qualified protection of personal data (hereinafter, “LQPD”), and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter, “GDPR”).

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. is committed to protecting the privacy of every user of our website and services. This Privacy Policy provides users with information regarding the processing of their personal data collected and processed through our portal.

1. IDENTIFICATION AND CONTACT DETAILS OF THE DATA CONTROLLER

• Company name: SEAFRONT CAPITAL TECHNOLOGIES, S.L.U.
• Tax ID (NRT): L-716181-P
• Registered address: Carrer del Fener 11-13, Andorra la Vella AD500, Andorra
• Email: info@addurno.com
• Website: www.addurno.com
• Activity: Real estate advertising portal specialized in frontline sea properties in Spain, Portugal and Italy

2. PERSONAL DATA WE COLLECT

At ADDURNO we collect and process the following personal data from users:

2.1. Browsing data

When you visit our portal, we automatically receive the URL of the website from which you came and the website you visit when leaving our portal. We also receive your Internet Protocol (IP) address, browser type, and the date and time of connection. This information is used to analyze global trends and improve the service. Additionally, other personal data may be automatically collected while you browse the portal, as described in our Cookie Policy.

Such analysis is carried out, where applicable, in aggregated form and for statistical purposes only.

Where the use of analytical cookies requires consent, such processing will only be carried out after acceptance in accordance with the Cookie Policy.

2.2. Data provided by the user

When you contact us, request property visits or subscribe to our services, we collect:

• Full name
• Email address
• Contact telephone number
• Property search preferences
• Postal address (optional)
• Information provided through contact or visit request forms

Data marked as mandatory are necessary to properly provide our services and manage user requests. Optional data are requested solely to improve user support and experience.

Data are collected through website forms, direct communications from the user and, where applicable, through the mechanisms described in the Cookie Policy.

3. PURPOSE OF DATA PROCESSING

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. processes personal data for the following purposes:

• Managing the website and improving user experience
• Request management: processing information and property visit requests
• Coordination with agencies: sharing information with collaborating real estate agencies to organize visits and manage requests
• Contacting and communicating with users
• Commercial communications: sending information about properties, services, products, offers or promotions of interest (with prior consent)
• Billing: issuing invoices for the advertising access service provided
• Service improvement: analyzing website usage to improve services and products
• Legal compliance: complying with legal and tax obligations
• Protecting and exercising rights or responding to claims
• Preventing and investigating fraudulent activities and ensuring service security

4. LEGAL BASIS FOR PROCESSING

The legal basis for processing personal data is as follows:

• Performance of a contract or pre-contractual measures: to manage information requests, visit requests and provide the requested advertising service.

• User consent: for sending commercial communications or newsletters, which will be expressly and separately requested in each case.

• Legal obligations: to comply with applicable legal, tax and accounting obligations.

• Legitimate interest: to improve portal security, prevent fraudulent use, enhance services and defend legal rights, always respecting users’ fundamental rights and freedoms.

5. DATA RECIPIENTS AND DISCLOSURE

Personal data are processed confidentially in accordance with the LQPD and the GDPR. Data may be disclosed to:

• Collaborating real estate agencies: to coordinate visits and manage information requests
• Technology service providers: hosting, website maintenance, email services (under confidentiality agreements and appropriate security measures)
• Competent authorities: where legally required

ADDURNO does not sell or transfer personal data to third parties for commercial purposes.

6. INTERNATIONAL DATA TRANSFERS

Andorra has been recognized by the European Union as providing an adequate level of data protection. Therefore, data processing carried out from the Principality of Andorra does not constitute a restricted international data transfer.

If, exceptionally, data were transferred to countries without an adequacy decision, such transfers would be carried out using appropriate safeguards provided by applicable law (such as Standard Contractual Clauses or other recognized legal mechanisms).

7. COMMERCIAL COMMUNICATIONS / NEWSLETTER

Commercial communications or newsletters will only be sent if the user has provided explicit consent. Consent may be withdrawn at any time via the unsubscribe link included in each communication or by contacting info@addurno.com.

8. PROFILING AND AUTOMATED DECISION-MAKING

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. does not carry out profiling or automated decision-making producing legal effects or similarly significant impacts on users.

9. ACCURACY AND UPDATING OF DATA

Users are responsible for ensuring that the personal data provided are accurate and up to date and for notifying any changes.

Inaccurate or incomplete data may exempt SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. from liability.

10. DATA RETENTION PERIOD

Personal data will be retained only for as long as necessary to fulfill the purposes for which they were collected or to comply with legal obligations.

Specifically:

• Active users: for the duration of the contractual or commercial relationship
• Leads/inquiries: up to 3 years from the last interaction
• Billing data: for the legally required period (minimum 5 years)

After these periods, data will be deleted or duly blocked and retained only for legal responsibilities.

11. SECURITY MEASURES

Appropriate technical and organizational security measures are implemented in accordance with the LQPD and GDPR to protect personal data against unauthorized access, alteration, loss or misuse.

12. USER RIGHTS

Users may exercise the rights of access, rectification, erasure, objection, restriction, portability, withdrawal of consent and not being subject to automated decisions.

Requests may be submitted via:

• Email: info@addurno.com
• Postal mail: SEAFRONT CAPITAL TECHNOLOGIES, S.L.U., Carrer del Fener 11-13, Andorra la Vella AD500, Andorra
• Contact form on www.addurno.com

Additional identification may only be requested where there is reasonable doubt as to the applicant’s identity.

Users may also lodge a complaint with the Andorran Data Protection Agency (APDA) or the competent authority in their place of residence.

13. MINORS

The ADDURNO portal is intended exclusively for users over 18 years of age. Data from minors are not intentionally collected and will be deleted immediately if detected.

14. INTELLECTUAL AND INDUSTRIAL PROPERTY

All website content, structure, design, source code, texts, images, domain names and trademarks are owned by SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. or licensed third parties and are protected by intellectual and industrial property laws.

15. LINKS TO THIRD-PARTY WEBSITES

ADDURNO is not responsible for the content, accuracy or availability of third-party websites accessed via links on the portal.

16. DISCLAIMER OF WARRANTIES AND LIABILITY

ADDURNO does not guarantee uninterrupted availability of the portal and shall not be liable, within legal limits, for damages resulting from technical failures or malicious elements.

17. CHANGES TO THE PRIVACY POLICY

SEAFRONT CAPITAL TECHNOLOGIES, S.L.U. reserves the right to modify this Privacy Policy. Changes will be published on the website with the updated date.

18. ACCEPTANCE

Access to and use of the portal implies full acceptance of this Privacy Policy.

19. APPLICABLE LAW AND JURISDICTION

This Privacy Policy is governed by Andorran law and the GDPR, without prejudice to mandatory consumer protection rules applicable according to the user’s place of residence. Disputes shall be submitted to the competent courts in accordance with applicable law.

20. CONTACT

For any questions regarding this Privacy Policy:

• info@addurno.com
• www.addurno.com
• Carrer del Fener 11-13, Andorra la Vella AD500, Andorra

Last updated: January 2026